Among the University of Colorado’s guiding principles is the commitment to “promote and uphold the principles of ethics, integrity, transparency and accountability.” Fostering a culture of ethics and compliance is a shared responsibility across the university community.
While “compliance” is a component of each employee’s job, in their particular roles many are more deeply engaged in promoting compliance with an increasingly wide variety of regulatory and other obligations in support of the university’s mission. The compliance community of practice is disbursed across many functional and academic units; community members work in a wide variety of management and front-line roles.
In August 2017, Internal Audit convened the first gathering of compliance community members from across the CU system in an informal setting with the goal of further developing collaborative relationships, sharing timely information, and supporting one another in their endeavors and professional growth. The three-hour event hosted at the system administration offices was very well received, with room capacity attendance of 45 individuals from across the university system. The agenda included a series of short presentations, interspersed with discussion facilitated by the audit manager for compliance.
In light of the enthusiastic response to the inaugural CUC2 event, Internal Audit hosted a second gathering with an expanded program in November 2018 on the CU Anschutz Medical Campus.
The intent of these events is not to duplicate the efforts of dedicated compliance working groups on the campuses and at system administration. Rather, CUC2 offers a collective venue for open discussion of various efforts to address compliance infrastructure, implementation and training issues, and for sharing expertise, experience, informational resources and practical tools across organizational “silos.”
The agenda for these discussions is driven by the expressed interests of the community and coordinated with designated campus compliance leaders. CUC2 gatherings are open to any employee who wishes to participate. Attendance is not predicated on holding a formal compliance role within the university.
CUC2 2018 built on the energy of the 2017 event, with 65 participants. The full-day program featured speakers from system administration and each of the campuses.
Vice President and University Counsel Patrick O’Rourke set the tone for the day with a presentation on the challenges of responding to emerging legal and regulatory risks in a volatile and uncertain environment, followed by a wide-ranging Q&A session. Topics discussed during the day included policy development, data privacy and security, addressing sexual misconduct, the operation of CU EthicsLine, and strategies for giving voice to values in engaging with ethical dilemmas.
CU Boulder Vice Provost William Kuskin wrapped up the event, pulling the many themes of the day together in a participative exploration of a passage from Chaucer’s “Canterbury Tales.”
Senior campus compliance leaders from across the system contributed to planning the event, and each had the opportunity to speak to the group assembled in the Gossard Forum in the Fulginiti Pavilion for Bioethics and Humanities. The fully in-the-round venue facilitated genuine interaction among community members throughout the program, as did opportunities to network informally during breaks and over lunch held in the Pavilion lobby and on the outdoor terrace.
Internal Audit anticipates developing future programs centered on a variety of timely themes. Preliminary discussion is taking place regarding a future gathering that may focus on ethics and compliance considerations relative to the university’s expanding global footprint and international engagement.
Submitted by Kathleen Sutherland, Department of Internal Audit.